A guide to
UCITS funds
in Cyprus
Fund Services
January 2016
kpmg.com.cy
Table of
contents
Introduction 1
UCITS Investment Policies4
Legal Framework of Cyprus UCITS
10
Main UCITS Counterparties15
Authorisation Procedure19
Marketing22
Reporting24
Taxation of UCITS in Cyprus
26
How Can KPMG Help?29
Introduction
Undertakings for Collective Investment in Transferable
Securities (“UCITS”) are collective investment schemes,
principally designed for retail investors, established and
authorised under the harmonised European Union (“EU”)
framework.
The main objective of the European UCITS framework has
been to create a single European market for retail investment
funds and to facilitate cross-border investment fund offers
for retail investors. At the same time it seeks to establish a
defined level of investor protection through strict investment
limits, as well as capital, organisational and disclosure
requirements. These objectives were introduced by the UCITS
I Directive 85/611/EC adopted on 20 December 1985, which
has been further amended by a number of subsequent EU
Directives aiming in continuously improving the product.
The latest UCITS Directive 2009/65/EC (“UCITS IV”) was
adopted by the European Council in 2009 and took effect on
July 1st 2011, while the latest recast, known as the UCITS
V Directive, is expected to be implemented by EU Member
States by March 2016. As a result of such developments,
UCITS can be marketed and sold to the public within the EU
on a passporting basis, based on its authorisation in one EU
Member State. Furthermore, the UCITS brand has become
recognised as a stable and well regulated product outside
the EU which explains the continuous growth of UCITS
distribution in Asia, Middle East and Latin America.
UCITS funds in Cyprus are governed by Law No. 78(I)/2012
(the “UCI Law”), transposing the UCITS IV Directive into
national law, and are regulated by the Cyprus Securities and
Exchange Commission (“CySEC”).
Key characteristics of the UCITS undertaking:
A UCITS is an undertaking:
• the sole object of which is the collective investment of
capital raised from the public in transferable securities
and/or other liquid financial instruments, as such are
referred to in the UCI Law;
• which operates on the principle of risk spreading; and
• the units/shares of which are, at the request of the
investor, redeemed or repurchased, directly or indirectly,
out of this undertaking’s assets.
A UCITS is not:
• a closed-ended undertaking for collective investment;
• an undertaking for collective investment which raises
capital without promoting the sale of its units/shares to
the public within the EU or any part of it;
• an undertaking for collective investment the units/
shares of which, under the terms of their constitutional
documents, may be sold only to the public in third
countries; or
• an undertaking for collective investment whose
investment and borrowing policies do not comply with
the conditions set in Chapter VII and article 83 of Directive
2009/65/EC.
A UCITS can not be converted to a non-UCITS.
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1
Why UCITS?
UCITS are considered a safe and transparent investment
product due to their liquidity, transparency, risk management
and high degree of regulation, which collectively offer
increased levels of investor protection and oversight. While
being addressed to retail investors, most UCITS are in fact
targeted at institutional investors who recognise the brand
as representing one of the highest standards in the asset
management industry.
Why Cyprus for UCITS?
Cyprus is an attractive UCITS jurisdiction with its clear and
prudent process for authorisation and supervision, cost
effective fee s tructure, high calibre service providers, and
efficient tax framework.
Cyprus – an attractive solution for the
establishment and operation of UCITS:
• Attractive tax environment with one of the lowest
corporate income tax rates in the EU and Eurozone at
12,5%, while fully complying with the EU Directives
and OECD requirements. Further, Cyprus offers full
exemption from tax on gains from trading in securities
• An extensive network of double tax treaties, giving
significant possibilities for international tax planning
through the island
• Rigorous anti-money laundering regulations complying
with EU Directives
• Modern and transparent legal system based on
Common Law
• Significant number of multinational companies and
international banking units, further enforcing the
productive and positive nature of the national economy
• Multilingual and highly educated workforce possessing
international professional qualifications
• Highly skilled service providers specialised in servicing
the fund industry, offering a wide range of customised
services in fund and acquisition structuring, fund
administration, custody and audit services
• Highly competitive professional services fees compared
to other European jurisdictions, without compromising
the level of quality of the service provided. A UCITS
applying for authorisation in Cyprus will have the
possibility to submit all required documentation as well
as subsequent reports and documents only in English,
reducing even more the costs of authorisation and
marketing
• Strategically located in the eastern Mediterranean sea
in the middle of three continents – namely Asia, Europe
and Africa – and offering a gateway to the Middle East,
providing access to investors in wealthy regions for
effective capital raising possibilities.
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3
UCITS Investment Policies
In an effort to offer adequate safeguards to investors,
UCITS are subject to specific investment restrictions –
relating both to the types of investments and the relevant
level of exposure. Despite these restrictions, UCITS may
accommodate an admittedly broad spectrum of investment
strategies.
Eligible Assets
UCITS are in summary permitted to invest in:
• transferable securities (“TS”) and money market instruments (“MMI”) which are either admitted to
official listing on a stock exchange in an EU or non-EU Member State or which are dealt in on another
regulated market which operates regularly and is recognised and open to the public;
• recently issued TS which will be admitted to official listing on a stock exchange or on another regulated
market (as described above) within one year of issue;
• MMI, other than those dealt in on a regulated market provided that the issue or the issuer is itself
regulated for the purpose of protecting investors and savings;
• units/shares of other UCITS or undertakings for collective investment (“UCI”) which are subject to
prudential regulation and supervision (subject to certain conditions);
• deposits with eligible credit institutions which are repayable on demand or have the right to be
withdrawn, and maturing in no more than 12 months; and
• financial derivative instruments (“FDIs”) dealt in on a regulated market or over the counter (“OTC”)
which meet certain criteria, among which that the underlying of the derivative consists of financial
indices, interest rates, foreign exchange rates, or currencies.
Some additional investment characteristics of a UCITS
include:
• A UCITS may invest in TS and MMI other than those
referred to above ( i.e unlisted TS and MMIs or those not
traded on a recognised exchange), but not exceeding more
than 10% of its assets
• A UCITS cannot acquire either precious metals or
certificates representing them, but is not prohibited from
investing in TS or MMI issued by a corporation whose main
business is concerned with precious metals. This does not
preclude the use of commodity ETFs
• A UCITS may hold ancillary liquid assets (cash)
• A UCITS established as a Variable Capital Investment
Company may acquire movable or immovable property
which is essential for the direct pursuit of its business.
Permitted Investment Limits
For the purposes of risk spreading and investor protection,
UCITS are subject to certain investment limits and restrictions
(expressed as a percentage exposure on its assets), as
defined in the UCI Law. The UCI Law allows UCITS to
derogate from the permitted investment limits for six months
following the date of its authorisation.
I. TS and MMI
(a)
10 / 5 / 40
No more than 10% of its assets in TS and MMI issued by the same body.
(∑ of all issuer exposures >5%) ≤40%
The aggregate value of TS and MMI in which the UCITS invests more than 5% of its assets in a single body, shall not exceed 40%.
Such limitation shall not apply to deposits or OTC derivatives transactions made with financial institutions subject to prudential supervision.
(b)
25 / 5 / 801
The 10% limit in (a) above increases to 25% where bonds are issued by a credit institution which is established in a Member State and is subject by law to special public supervision designed to protect bond-holders.
(∑ of exposures to single body >5%) ≤80%
The aggregate value of bonds issued by a single issuer in which the UCITS invests more than 5% of its assets shall not exceed 80%.
(c)351
The 10% limit in (a) above increases to 35% if the TS or MMI are issued or guaranteed by a Member State, by its local authorities, by a third country or by a public international body to which one or more Member States belong.
(d)
100 / 6 / 30
Under specific authorisation from CySEC, the limit of 35% in (c) above increases to 100% if CySEC considers that unitholders have protection equivalent to that of UCITS unitholders and subject to certain conditions.
In such a case, the UCITS shall hold securities from at least 6 different issues, but securities from any single issue shall not account for more than 30% of the total assets of the UCITS.
1. These investments are not taken into account for the purpose of applying the 40% limit in the first rule.
II. Units/Shares of other UCITS or UCIs1&2
(a)20
No more than 20% of its assets in units of a single UCITS or other UCI (each sub-fund of an underlying umbrella UCITS may be regarded as a separate UCITS in this regard).
(b)30
Investments made in UCIs other than UCITS shall not exceed 30% in aggregate.
1. A UCITS may acquire no more than 25% of the units/shares of the underlying UCITS or UCI (or the aggregate amount invested in one or
more sub-funds of an umbrella UCITS).
2. Such UCITS or UCI cannot itself invest more than 10% in other UCITS or UCIs.
A guide to UCITS funds in Cyprus
5
III. Deposits with Credit Institutions
(a)20
No more than 20% of its assets in deposits made with the same body.
IV. Financial Derivative Instruments1
(a)10
The risk exposure to a counterparty of the UCITS in an OTC derivative transaction shall not exceed 10% of its assets when the counterparty is a credit institution having its registered office in a Member State or, if in a third country then provided that it is subject to prudential rules considered by CySEC as EU equivalent.
(b)5 The risk exposure to a counterparty cannot exceed 5% of its assets in all other cases.
1. UCITS that use derivatives either for investment or for Efficient Portfolio Management (“EPM”) purposes must prepare a relevant Risk
Management Process Statement which sets out the types of derivatives that the UCITS will use, the risk associated with such derivatives,
and how those risks are managed and controlled. It must also make appropriate disclosures in the UCITS Prospectus.
V. Combined limits per issuer
(a)20
Notwithstanding the limits noted in I(a), (b) & (c), and III(a) above, a UCITS shall not combine, where this would lead to investment of more than 20% of its assets in a single body, any of the following:
-
TS or MMIs issued by that body;
-
Deposits made with that body; or
-
Exposures arising from OTC derivative transactions undertaken with that body.
(b)35
The limits provided for in I(a), (b) & (c), III(a), and IV(a) & (b) above shall not be combined, and thus investments in TS or MMIs issued by the same body or in deposits or derivative instruments made with this body carried out in accordance with these rules shall not exceed in total 35% of the assets of the UCITS.
(c)20
Companies included in the same group for the purposes of consolidated accounts, as defined in Directive 83/349/EEC or in accordance with recognised international accounting standards, shall be regarded as a single body for the purposes of calculating investment limits; the cumulative investment in companies within the same issuing group is permitted up to a limit of 20% of the UCITS’ assets.
VI. Financial Indices
(a)20
A UCITS whose objective under the basis of its constitutional documentation replicates the composition of a certain stock or debt securities index may have a maximum exposure to shares or debt securities issued by a single body of 20% of its assets (instead of 10%).
(b)35 This 20% limit increases to 35% for maximum one issuer where that proves to be justified by exceptional market conditions (eg. regulated markets where certain TS or MMI are highly dominant).
VII. Efficient portfolio management (“EPM”) techniques and instruments
A UCITS is permitted to use EPM techniques and instruments relating to TS and MMI, including securities lending,
reverse repurchase/repurchase transactions and financial derivatives subject to certain restrictions prescribed in the
UCI Law. Such transactions are to be economically appropriate and shall be exclusively entered into for one or more of
the following specific aims: (i) reduction of risk, (ii) reduction of cost and (iii) generation of additional capital or income
for the UCITS with a level of risk which is consistent with the risk profile of the UCITS and the risk diversification rules
applicable to them. Financial derivatives used for EPM purposes must comply with normal rules applicable in the UCI
Law for investment in financial derivative instruments (IV above).
The use of EPM techniques and a description of the inherent risks, as applicable, must be explicitly disclosed in the
UCITS’ Prospectus.
VIII. UCITS with guaranteed assets or guaranteed performance
A UCITS with guaranteed assets or guaranteed performance is permitted where the guarantee is provided by a credit
institution established in Cyprus or another Member State but with a branch in Cyprus and cannot be the Depositary or
any other credit institution to which depositary services have been delegated.
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7
Prohibition to Acquire Control
A UCITS shall not acquire any shares carrying voting rights
which would enable them to exercise significant influence
over the management of an issuing body.
A UCITS may acquire no more than:
• 10% of the non-voting shares of a single issuing body; or
• 10% of the debt securities of a single issuing body; or
• 25% of the units of a single UCITS or other UCI; or
• 10% of the MMI of a single issuing body.
The above three limits may be disregarded at the time of
acquisition if at that time the gross amount of the debt
securities or of the MMI, or the net amount of the securities
in issue, cannot be calculated.
All the above limits are disapplied in certain circumstances
such as TS and MMI issued or guaranteed by a Member State
or its local authorities.
Borrowing Restrictions and Prohibition of
Credits and Guarantees
In principle neither a UCITS, nor a Management Company
acting on behalf of a UCITS, may borrow. There are three
exceptions to this rule:
(1) Provided that such borrowing is on a “temporary basis”
(i.e may not exceed a certain duration) and represents no
more than 10% of the net asset value of the UCITS; or
(2) To enable the acquisition of immovable property essential
for the direct pursuit of its business, in the case of a
Variable Capital Investment Company, but representing
no more than 10% of the net asset value of the UCITS.
(3) To acquire foreign currency by means of a “back-to-back”
loan, under certain conditions.
The combined amounts of borrowings under (1) and (2) above
shall not exceed 15% of its net asset value in total.
It is important to note that despite the above, UCITS can be
leveraged up to 100% of its net assets through the use of
FDI’s.
A UCITS shall not grant loans or act as a guarantor on behalf
of third parties. This does not preclude the acquisition of TS
which are not fully paid.
UCITS Investment Strategies
Investment strategies that may be pursued by UCITS, subject always to
compliance with the rules on eligible assets and permitted investment limits
in the UCI Law, range from relatively plain vanilla equity and bond products
through to alternative strategies previously confined to funds targeting
institutional investors or high net worth individuals. Indeed, asset managers
may choose to replicate alternative strategies under UCITS as a means to
access capital from retail investors that are more comfortable investing in
more regulated structures and concurrently from institutional investors who
may be restricted from investing in unregulated or lightly regulated products.
Examples include:
• Money market funds
• Capital or Performance Guaranteed funds
•Fund-of-Funds
• Index Tracking funds
• Exchange Traded funds (ETFs)
• Structured products
• Futures funds
• Long/short equity funds (eg. 130-30)
• Socially Responsible Investments
• Absolute Return funds
UCITS Structuring Possibilities
Master-Feeder structure
-Feeder Fund invests a
minimum of 85% of its assets in
the Master; the remaining 15%
can only be used for ancillary
liquid investments, derivatives
for hedging purposes or
movable and immovable
property essential for the
business of the Feeder
-Master Fund has at least one
Feeder, cannot hold any shares
in any feeder, must not be a
feeder itself , and cannot charge
the feeder any subscription/
redemption fees
Fund-of-Funds
-Possible to invest in other
UCITS or UCIs, subject to
compliance with the eligibility
conditions and investment
limits prescribed by the UCI
Law
Fund with multiple investment
compar tments
Single
Stand-Alone
Fund
Umbrella
Fund
MasterFeeder Fund
-May have multiple investment
strategies represented by the
different compartments
-Each compartment
corresponds to a distinct
portfolio of assets and
liabilities
-Cross investment possible
(subject to restrictions)
UCITS Fund
Structure
Fund-ofFunds
Multi-Class
Fund
Funds with one or more
classes of units/shar es
-Multiple classes based on
investor type, geographical
market, fee structure, currency,
hedging, etc.
A guide to UCITS funds in Cyprus
9
Legal framework of Cyprus UCITS
Regulator
CySEC is the independent public authority responsible
for the supervision of the investment services market
and transactions in transferable securities carried out in
Cyprus. Among others, it is the regulatory and supervisory
authority with powers to grant operation licences to all
investment funds - UCITS and AIFs - UCITS Management
Companies, Alternative Investment Fund Managers (AIFMs),
and Investment Firms licenced and operating under the
implementing legislation of Markets in Financial Instruments
Directive (MiFID).
A key strength of CySEC is its flexibility and accessibility
as a regulator, which has been achieved through its close
cooperation with the private sector and its willingness to
be open to discussions and suggestions from the industry
on ways to improve its services and the sector. CySEC
operates an open-door policy and is willing to meet with
fund promoters and work through practical solutions. It is
further committed to the continuance and enhancement of
cross-border collaboration, both at an EU level and with third
countries.
Legal Forms
In Cyprus, UCITS can either take the form of a Common
Fund or a Variable Capital Investment Company. The main
characteristics of each of the legal structures are given in the
table below.
Variable Capital Investment
Company (VCIC)
Common Fund (CF)
Legal structure &
constitutional documents
Key features
Contractual vehicle;
Corporate vehicle;
Constituted under Contract Law by way
of a Common Fund regulation drawn
jointly by the Management Company and
Depositary).
Incorporated under the Companies Law Cap
113 as a public company with liability limited
by shares;
Has no legal personality and acts through
the Management Company;
Increase or reduction of share capital
is automatic, without following the
formalities of the Companies Law Cap.
113
Undivided co-ownership of assets
between unitholders.
Memorandum and Articles of Association.
Legal requirement
for appointment of a
Management Company
Yes.
Yes, unless self-managed.
Governance body
Board of Directors of Management Company.
Board of Directors.
Participation
Fully paid up and registered units of no par
value;
Fully paid up and registered shares of no
par value;
Fractions of units can be issued.
Fractions of shares can be issued.
Tax transparency
Yes.
No.
Role of Investors
Advisory role, whose decisions at a
meeting do not bind the Management
Company.
Investors may decide on the dissolution
and merger of the VCIC.
Reporting
Audited annual report;
Same as CF.
Unaudited semi-annual report.
Financial year
Calendar year;
Same as CF.
First financial year ends on the 31st of
December of the first calendar year of
operation of the UCITS.
Issue price of units/shares
Based on NAV per unit.
Based on NAV per share.
Frequency of Calculation
and publication of value
of units
At least every fortnight, on the first
business day,
Same as CF, and daily calculation in
the case of a tradable UCITS.
Published on the website of the UCITS or
the Management Company, as applicable,
on the business day after the said
calculation.
Valuation of assets and
liabilities
Valued at fair value in accordance with IFRS.
Same as CF.
Listing possibilities
Units may be admitted without trading
on a stock exchange market operating in
Cyprus or any Member State, or a third
country provided by CySEC has signed
with the relevant competent authorities
a memorandum of cooperation and
exchange of information.
May be admitted without trading on a stock
exchange market operating in Cyprus or any
Member State, or a third country provided
by CySEC has signed with the relevant
competent authorities a memorandum of
understanding and exchange of information.
May also be admitted for trading in a
regulated market of tradable UCITS or a
multilateral trading facility of tradable UCITS
operating in Cyprus or another Member State,
provided that certain cumulative conditions
are met.
A guide to UCITS funds in Cyprus
11
Umbrella Funds
The Law allows for the creation of a UCITS, regardless of
its legal form, as an Umbrella fund with several investment
compartments (i.e. sub-funds) where each compartment
corresponds to a distinct portfolio of assets and liabilities of
the UCITS:
Objective
May accommodate different:
• investment policies;
• reference currencies;
• categories of investors; and
• structure of fees and minimum subscription requirements.
One single entity
The UCITS constitutes a single legal entity.
Ring fencing
Each compartment is liable for the obligations arising from its constitution,
operation or dissolution unless the constitutional documents of the UCITS provide
otherwise.
Conversion
Possibility to convert from one compartment to another.
Cross-investment
A compartment of a UCITS may invest in another compartment of the same
UCITS (compartment target), if provided in its Constitutional Documentation,
subject to conditions (see graph below).
The investment restrictions imposed by the UCI Law also apply to the crossinvestment of a UCITS compartment into another compartment of the same
UCITS.
In such a case:
• Voting rights (if any) corresponding to the units/shares invested in the target are
suspended;
• The value of the units/shares invested in the target is not calculated twice in the
valuation of the net assets of the UCITS;
• There is no duplication of management, distribution, redemption or re-purchase
fees concerning investments of one compartment into another compartment
of the same UCITS.
Dissolution / Liquidation
Each compartment is dissolved and goes into liquidation separately; the
dissolution or liquidation of a compartment does not lead to the dissolution or
liquidation of the other compartments of the UCITS.
Umbrella Fund
Sub-Fund A
Sub-Fund A
invests no
more than
20% of its Net
Assets in each
other SubFund
X
X
Sub-Fund B
Sub-Fund C
Sub-Fund D
Sub-Fund E
Sub-Fund F
20%
20%
20%
20%
20%
X
Sub-Funds B, C, D, E & F
may not invest in SubFund A (no circle
investment)
Total Investments of Sub-Fund A into the other SubFunds must not exceed 25% of the Net Assets of the
entire Umbrella Fund
10%
Target Sub-Funds must
not invest more than
10% in aggregate of their
Net Assets in other SubFunds of the Umbrella
Fund
A Sub-Fund is not allowed to invest in another SubFund if the latter has invested more than 10% of its
assets in other UCITS or UCIs
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13
Main UCITS Counterparties
A UCITS needs to appoint a number of key counterparties
which are:
AML
Compliance
Officer
Auditor
Management
Company
Investment
Manager
UCITS Fund
Depositary
Distributor(s)
If appointed; otherwise,
Board of Directors of
self-managed VCIC
Delegate (if appointed)
of Management
Company or Board of
Directors of selfmanaged VCIC
Fund
Administrator
Required independent
party
May be performed by a
member of the Board of
Directors of
Management Company
or of VCIC
The appointment and/or replacement of any of the key
counterparties (except the Distributor and Auditor) of a
Cyprus UCITS, and the terms of the agreement to which the
appointment is subject, must be approved by CySEC prior to
such appointment.
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15
Management Company
Activities
The management of a UCITS, for the purposes of the Law, shall include the following
functions:
• Investment Management;
• Administration:
o Legal and UCITS management accounting services;
o Provision of information and service of the UCITS’ unit-holders;
o Valuation of the UCITS’ portfolio and pricing of units, including taxation issues;
o Regulatory compliance monitoring;
o Maintenance of unit-holder register;
o Distribution of profits of the UCITS;
o Unit issue, redemption and repurchase;
o Settlement of contractual obligations, including the dispatch of documents and
certificates;
o Record keeping;
• Advertising of the UCITS and the promotion of its units (marketing).
Management Companies are also authorised to provide additional services, such
as discretionary management of individual client portfolios, or as non-core services,
investment advice or safekeeping and administration of UCI units. The provision of such
additional services requires compliance with MiFID regulations as applicable in the Member
State of authorisation.
Authorisation
The Management Company has to be authorised in Cyprus or any other EU Member State
under the provisions of the UCITS IV Directive. Once authorised, it is granted a passport for
performing its services cross-border.
Authorisation of a UCITS Management Company in Cyprus can be granted by CySEC,
provided a number of conditions are met:
• Capital of EUR 125,000 plus additional own funds of 0.02% of assets under management
exceeding EUR 250 million, subject to a maximum of EUR 10 million; at no time be less
than 25% of the preceding year’s fixed overheads;
• Fit and proper persons (minimum two) conducting the business of the Management
Company;
• The application must be accompanied by a document containing the programme of
activity, risk management process, the organisational structure, human and technical
infrastructure, delegation arrangements, details of shareholding, and of external auditor.
Localisation Requirement
Delegation
The UCITS Management Company may be located in Cyprus or any other EU Member State.
The Management Company is authorised to delegate any of its functions subject to certain
conditions and eligibility requirements as prescribed in the UCI Law. In addition the following
conditions must be satisfied:
• Disclosure of the delegation in the Prospectus;
• Extent of delegation may not reduce the Management Company or self-managed UCITS
to a letter box entity;
• Initial and ongoing due diligence on the delegate;
• Delegation must not prevent effectiveness of supervision;
• Implementation of control arrangements to access data documenting the activities of the
delegate;
• Possibility to give instructions to the delegate and to withdraw the mandate with
immediate effect.
Depositary
Activities
The Depositary is entrusted with the following duties1:
• Safe-keeping of the assets of the UCITS; and
• Monitoring of the assets of the UCITS (i.e know at any time where the assets of the
UCITS have been invested and where and how such assets are available).
The Depositary is entrusted with additional supervisory functions which extend to:
• Ensuring that the issue, the marketing, the redemption, the re-purchase and the
cancellation of units/shares, entries of any kind in the Unit/Share-holders’ Register, as
well as the valuation of units/shares are properly carried out in accordance with the
applicable legislation and the UCITS constitutional documents;
• Ensuring the payment of the price for the transactions concerning the assets of the
UCITS, within the usual deadlines;
• Ensuring that the UCITS profits are distributed according to the applicable legislation and
the UCITS constitutional documents;
In addition for UCITS established as a Common Fund, the Depositary must also:
• Execute the orders of the Management Company, unless these conflict with the
applicable legislation or to the Common Fund regulation and monitor the correct
execution of its orders by the Management Company.
Eligibility Requirements
Must be an authorised credit institution, or another entity on condition that it is entitled
under its relevant operation license to provide depositary services, and is further subject
to (among others) capital adequacy requirements and prudential regulation and ongoing
supervision.
Such an institution can act as depositary of a UCITS only if it is approved to do so, and
provided it can demonstrate that it has the necessary human and technical infrastructure in
place to properly fulfil its duties and obligations.
The Depositary and Management Company may belong to the same group of companies,
but they shall be obliged to act independently from one another and exclusively in the
interests of all unitholders.
Localisation Requirement
Must have its registered office in Cyprus, or its seat in a Member State and a branch in
Cyprus.
Delegation
The Depositary may assign the safekeeping of the assets of the UCITS to a third party if so
entitled under the UCITS regulations or instruments of incorporation. The assignment to an
authorised depositary abroad is allowed subject to certain conditions been met.
Liability Regime
• Is liable to the Management Company and unit/share-holders for any losses suffered by
them due to violation of its obligations.
• Shall be fully liable together with any third party to whom it assigned assets for
safekeeping, for the loss caused to the Management Company or unitholders.
Exemptions
UCITS whose units have been admitted to official listing in Cyprus or another EU stock
exchange are not required to appoint a Depositary, subject to fulfilling certain conditions
1. Changes to be expected under UCITS V; framework to be aligned with AIFMD clarifying new safe-keeping, oversight and cash monitoring duties.
A guide to UCITS funds in Cyprus
17
Other Service Providers
Fund Administrator
Is subject to CySEC prior approval.
May be appointed by the Management Company or UCITS itself, as the case may be, to
perform the administration tasks noted under the Management functions of the UCI Law.
Must be of sufficient repute and experienced enough and have the necessary human and
technical infrastructure in place to properly fulfil its duties and obligations.
Investment Manager
Is subject to CySEC prior approval. Must be authorised for the purpose of asset
management and is subject to prudential regulatory supervision.
The investment manager does not need to be located in Cyprus. If located in third countries,
there must be a cooperation agreement between CySEC and the supervisory authority of
the investment manager.
Distributor
Is an intermediary either actively participating in the marketing of the shares/units of the
UCITS or appointed as being authorised to receive subscription and redemption orders.
The distributor can be the Management Company itself, a credit institution, a firm providing
investment services or other Management Companies.
The marketing of the UCITS units is effected in accordance with the provisions of the
Investment Services and Activities and Regulated Markets Law which regulate the
investment services of reception and transmission of orders.
Paying Agent
Is the professional who receives the monies from investors and pays investors (in case of
redemption or dividend payments). The UCITS shall ensure the appointment of this person
is made in accordance with the laws, regulations and administrative provisions in force in
the Member State in which the UCITS will register to market its units/shares.
Auditor
Anti-Money Laundering
(“AML”) Compliance
Officer
Must be located in Cyprus.
Must be independent of the Management Company or the UCITS itself, as the case may be.
Responsible for, among others:
• Reviewing the annual accounts;
• Reviewing the activities of the UCITS and its compliance with domestic rules and the
constitutional documents;
• Carrying out specific reporting duties to CySEC: prompt reporting of any fact or decision
of which it has become aware and which is likely to constitute a material breach of law or
the constitutional documents; any situation which might lead to the refusal to certify the
accounts or require the expression of qualifications thereon.
An AML Compliance Officer needs to be appointed in accordance with the CySEC
Directive 144-2007-08 issued in February 2009. The names and positions of persons
appointed from time to time should be communicated to CySEC.
The AML Compliance Officer may also be a member of the Board of Directors of the
Management Company or the UCITS itself, as the case may be.
The AML Compliance Officer is responsible for the implementation of the Anti-Money
Laundering Manual of the UCITS which provides the guidelines that should be followed
throughout to assist in the detection and/or prevention of money-laundering activities in
accordance with the relevant instruments issued by CySEC.
Authorisation Procedure
The application is submitted by the Management Company
or UCITS itself, if self-managed. The operation licence once
granted is valid for all EU Member States.
The Management Company or UCITS itself, as the case
may be, shall give notice to CySEC of any change that may
occur as regards any information on the basis of which the
operation licence is granted.
The main requirements for obtaining authorisation are set out
below, depending on the legal form.
Common Fund
Minimum capital
requirements
Fund documentation
EUR 200.000 payable within 3 months from the grant of the licence.
For umbrella funds, minimum capital applies for each compartment.
• Application form completed by proposed Management Company;
• Declaration of undertaking the obligation to pay initial minimum capital;
• Draft Common Fund regulation;
• Draft Prospectus;
• Draft Key Investor Information;
• Declaration of Depositary;
• Material Agreements;
• Risk Management Process Statement (if investing in or using derivatives).
Management Company
approval
UCITS Management Company authorised under UCITS IV Directive, with head and
registered offices in Cyprus or another EU Member State.
If established in another EU Member State, need an Information Flow Agreement with the
Cyprus-based Depositary.
Depositary approval
Must be a credit institution or another entity (on condition that it is authorised to provide
depositary services and is further subject to (among others) capital adequacy requirements
and prudential regulation and ongoing supervision), with registered office in Cyprus, or
registered seat in another member state and a branch in Cyprus.
Must dispose of necessary infrastructure for performing the tasks of safe-keeping and
monitoring.
Must designate at least two Directors of sufficient repute and experience responsible to
manage or monitor the activity of the CF.
A guide to UCITS funds in Cyprus
19
20 | Alternative Investment Fund Managers (AIFMs)
VCIC
Minimum capital
requirements
EUR 200.000 fully paid-up in cash upon constitution;
EUR 300.000 if self-managed.
For umbrella funds, minimum capital applies for each compartment.
Fund documentation
• Application form completed by proposed Management Company or Board of Directors (if
self-managed);
• Confirmation regarding the existence of initial minimum capital;
• Draft Memorandum & Articles of Association;
• Draft Prospectus;
• Draft Key Investor Information;
• Declaration of Management Company (if appointed);
• Declaration of Depositary (if appointed);
• Material Agreements;
• Risk Management Process Statement (if investing in or using derivatives);
• Personal Questionnaire completed by each member of the Board of Directors;
• Confirmations of the Auditor, Legal Advisor and promoter of the application.
Additional documents
where the VCIC is selfmanaged
• At least two executive Directors of sufficient repute and experience in relation to the type
of investment pursued;
• Business Plan (programme of activities);
• Programme of operation including the organisational structure and risk management
systems, sound administrative and accounting procedures, control and safeguard
arrangements for electronic data processing and adequate internal control mechanisms
including, in particular, rules for personal transactions by its employees.
Management Company
approval
If appointed, UCITS Management Company authorised under UCITS IV Directive, with head
and registered offices in Cyprus or another EU Member State.
If established in another EU Member State, need an Information Flow Agreement with the
Cyprus-based Depositary.
Depositary approval
Must be a credit institution or another entity (on condition that it is authorised to provide
depositary services and is further subject to (among others) capital adequacy requirements
and prudential regulation and ongoing supervision), with registered office in Cyprus, or
registered seat in another member state and a branch in Cyprus.
Must dispose of necessary infrastructure for performing the tasks of safe-keeping and
monitoring.
Must designate at least two Directors of sufficient repute and experience responsible to
manage or monitor the activity of the VCIC.
Exemption from the obligation to appoint a Depositary where at least 80% of the shares of
the VCIC have been admitted to official listing in a stock exchange operating in the Republic
or another Member State and other requirements are met.
Approval Time
In the case of a UCITS that has appointed a Management Company, such
Management Company shall be informed within two months from the
submission of the complete application file whether the operation licence of
the UCITS has been granted or not.
In the case of a self-managed VCIC, the UCITS shall be informed within six
months from the submission of the complete application file whether the
operation licence of the UCITS has been granted or not.
Reasons shall be given where the grant of a licence is refused. In case of a
VCIC, whether or not it has appointed a Management Company, the decision
of CySEC not to grant the operation licence shall be also communicated to the
Registar of Companies within the above time period, as the case may be.
Application and Annual Fees*
Description
Application (€)
Annual (€)
Operation licence of a UCITS with
no investment compartments.
1.800
1.800
Operation licence of a UCITS with
several investment compartments.
1.800 plus:
1.800 plus:
(i) sub-funds 2-15,
400 each;
(i) sub-funds 2-15,
400 each;
(ii) sub-funds 16+,
250 each
(ii) sub-funds 16+,
250 each
Operation licence of self-managed
VCIC with no investment.
2.500
1.800
Operation licence of self-managed
VCIC with several investment
compartments.
2.500 plus:
1.800 plus:
(i) sub-funds 2-15,
400 each;
(i) sub-funds 2-15,
400 each;
(ii) sub-funds 16+,
250 each
(ii) sub-funds 16+,
250 each
Amendment to constitutional
documents.
250
Transfer of Cyprus UCITS to
another Member State.
250
* in accordance with CySEC Directive DI78-2012-34 dated 15/10/ 2012.
UCITS which have not started operating within the calendar year they
are granted the licence, shall pay annual fees to CySEC for the specific
calendar year. In this case and in the case of a newly established UCITS, the
annual contributions shall be calculated in proportion, based on the date of
communicating to the Management Company or to the UCITS itself, as the
case may be, the grant of licence by CySEC.
A guide to UCITS funds in Cyprus
21
Marketing
Within the EU, UCITS benefit from the EU “passport”
available under the UCITS directive and are thus freely
marketed on a public basis within all Member States without
additional authorisation from the competent regulatory
authority of each “host” Member State. This is subject to a
successful completion of a “notification” process described
below. Outside the EU UCITS must satisfy local regulations
significantly more complex and time consuming than the
notification process introduced under UCITS IV.
It is important to note that the UCITS may be advertised
only after the operation licence is communicated to the
Management Company or the UCITS itself, as the case may
be.
Furthermore, distribution of UCITS funds into selective
jurisdictions via private placement is becoming increasingly
common as opposed to public distribution.
of a branch or under the freedom to provide services,
accordingly the notification letter shall include an indication
of this fact.
A UCITS shall enclose with the notification letter the latest
version of the following documents:
• constitutional documents;
•prospectus;
• latest annual and half-yearly report (if applicable); and
• key investor information document (“KIID”).
The above documents shall be translated into the official
language of the host Member State or into a language
approved by the competent authorities of that Member
State or (for documents other than the KIID) into a language
customary into the sphere of international finance.
• The notification letter shall include information on
arrangements made for marketing units of the UCITS in
the host Member State, including, where applicable, the
categories of units/shares to be marketed.
CySEC shall verify the completeness of the documentation
submitted and in case it considers it complete, it shall
transmit to the competent authorities of the Member
State where the UCITS shall market its units/shares
the information and the documentation along with an
attestation that the UCITS fulfils the conditions imposed
by the UCITS IV Directive no later than 10 working days
of receipt of the notification letter accompanied by the
complete documentation. Upon the transmission of the
documentation, CySEC shall immediately notify the UCITS
about the above transmission. The transmission and filing of
the information, documentation, and of the above attestation
may also be performed via electronic means.
• In the case that the units/shares of a UCITS are marketed
by its Management Company, in the context of its
cross-border business within the territory of the UCITS’
host Member State, either through the establishment
The UCITS may start marketing its units/shares within the
territory of the UCITS’ host Member State as from the date
CySEC notifies it of the above transmission to the competent
authorities of the UCITS’ host Member State.
Marketing of units/shares of Cyprus UCITS in the
EU - regulator-to-regulator notification
The required steps are as follows:
• A UCITS authorised in Cyprus that proposes to market its
units/shares in a Member State other than Cyprus, shall
previously submit a notification letter to CySEC.
UCITS (Cyprus)
Notifies UCITS of the date of
transmission
Submits notification file including a
notification letter accompanied by:
UCITS may be marketed in the Host
Member State as of the date of the
above notification from CySEC
-Constitutional documentation
-Prospectus
-Latest annual and half-yearly report
-KIID
CySEC
(Home Member State)
Host Member State performs ex-post
checks of marketing arrangements in
accordance with local marketing rules
If file is considered complete, it shall
transmit it to the competent authorities
of the Host Member State along with an
attestation that the UCITS fulfils the
conditions imposed by the UCITS IV
Directive
File is transmitted no later than 10
working days from receipt
Host Member State
As such a UCITS authorised in one EU Member State can
not be prohibited from selling or promoting the sale of its
units/shares to the public in any other EU Member State,
provided that the competent regulatory authority in that other
Member State has been notified of its intended activities.
The UCITS must, however, comply with local marketing and
advertising requirements. Indeed the UCITS directive does
not harmonise or include rules regarding the way in which the
UCITS should be sold in each Member State. As an example
in almost all Member States a UCITS must appoint a local
paying agent in addition to ensuring it remains in compliance
with each jurisdiction’s marketing and selling rules.
Marketing of units/shares of Cyprus UCITS via
private placement
An alternative to authorisation for public distribution is by way
of private placement. This is a strategy that may be adopted
by UCITS that seek to target a small number of larger
institutional investors. However, there are no harmonised
rules within the EU surrounding private placement and
thus fund promoters must contend with the specific local
regulations governing private placement in every jurisdiction
of intended distribution.
Marketing of units/shares of Cyprus UCITS
outside the EU
The UCITS passporting regime is not available when
considering the marketing of units/shares of UCITS outside
the EU. A UCITS must therefore be registered under the local
regime and comply with all local registration and compliance
requirements.
A guide to UCITS funds in Cyprus
23
Reporting
Reporting to the Regulator and the investors
The Management Company or the UCITS itself, if selfmanaged, draws up and submits to CySEC and makes
available to the investors at all selling points of units/shares
the following:
Prospectus
• Shall include, among others:
o information necessary for investors to be able to make an informed judgement of the
investment proposed to them, and in particular, of the risks attached thereto;
o a clear and easily understandable explanation of the UCITS’ risk profile;
o an indication of the categories of assets in which the UCITS is authorised to invest;
o disclosure of whether transactions in financial derivatives instruments are authorised,
in which case it shall include a prominent statement indicating whether those
operations may be carried out for the purpose of hedging or with the aim of meeting
investment goals, as well as the possible outcome of the use of financial derivative
instruments on the risk profile;
o procedures and conditions for the issue/sale and redemption of units/shares;
o determination of the issue/sale price and the redemption price of units/shares as well
as all related costs and charges; and
o identification of the appointed key counterparties.
• The essential elements of the Prospectus shall be kept up to date.
Key Investor Information
Document (“KIID”)
• A two-page document (three-page for structured products) containing appropriate
information about the essential characteristics of the UCITS concerned, which is to be
provided to investors so that they are reasonably able to understand the nature and the
risks of the investment product that is being offered to them and, consequently, to take
investment decisions on an informed basis;
• Shall be delivered to the prospective investor (or intermediaries) prior to their investment
in the UCITS.
Annual Report
• Prepared for each financial year, within four months from the end of the period to which it
refers.
• Shall include in particular:
o a statement of financial position or a statement of assets and liabilities, and a detailed
income and expenditure account for the financial year;
o a report on the activities of the financial year;
o any significant information which will enable investors to make an informed judgment on
the development of the activities of the UCITS and its results; and
o other information as provided in Schedule II of the Annex of the UCI Law (such as number
of units in circulation, net asset value per unit) as this may be required by CySEC.
• The accounting information given in the annual report shall be audited by one Auditor
according to International Audit Standards. The Auditor’s report, including any reservations
of the Auditor, shall be reproduced in full in each Annual Report.
Half-Yearly Report
• Drawn up in accordance with International Accounting Standards covering the first six
months of the financial year, within two months from the end of the period to which it
refers.
• Shall include in particular:
o interim financial statements;
o other information provided for in Schedule II of the Annex of the UCI Law and as this
may be required by CySEC.
• Where a UCITS has distributed or intends to distribute an interim dividend, the figures
contained in the report shall indicate the results after the deduction of the tax, charges
and other rights or expenses for the half-year concerned as well as the interim dividend
that has been distributed or is to be distributed.
In case the UCITS comprises more than one investment
compartment, a single prospectus, KIID, and single reports
and statements as referred to above shall be prepared for
each investment compartment of the said UCITS.
Key Investor Information
Features and content
The KIID shall be written in a concise manner and nontechnical language that is comprehensible to retail investors,
and provide information on the following essential elements
in respect of the UCITS concerned:
• identification of the UCITS, including the share class or
investment compartment (if applicable);
• identification of the Management Company appointed (if
applicable);
• a short description of its investment objectives and
investment policy;
• risk/reward profile of the investment (via the use of a
synthetic indicator, further explained below), including
appropriate guidance and warnings in relation to the risks
associated with investments in the relevant UCITS;
• costs and associated charges;
• past-performance presentation (if available) based on the
net asset value of the UCITS; and
• other practical information such as identification of
depositary appointed, as well as where, how and in which
language to obtain the Prospectus and any other further
information about the UCITS.
Publication
The KIID is available in paper copies and also uploaded on the
website of the Management Company or the VCIC, and is
provided to the potential investors either in a durable medium
or through the internet. A paper copy shall be delivered to
the investor on request and free of charge. In addition, an
up-to-date version of the KIID shall be made available on the
website of the Management Company or the VCIC.
Review and update
A review of the KIID shall be carried out at least every twelve
months and any update shall be made available promptly. A
KIID with duly revised presentation of past performance of
the UCITS shall be made available no later than 35 business
days after 31 December each year.
In addition, a review shall be carried out prior to any proposed
change to the Prospectus and/or constitutional documents.
A revised KIID in such case shall be made available promptly
and prior to such change coming into effect.
Publication of other information
The UCITS’ net asset value, the number of its current units/
shares, the unit/share net asset value, the subscription and
redemption or repurchase price are calculated every fortnight
on the first business day (or, in the case of a tradable UCITS,
daily) by the Management Company and are published the
business day after the aforementioned calculation, on the
website of the Management Company.
The synthetic indicator mentioned above should rank the
UCITS and depict the information accordingly on a scale
of 1 to 7 on the basis of its volatility record using weekly
or monthly returns concerning the previous five years (if
applicable).
A guide to UCITS funds in Cyprus
25
Taxation of UCITS in Cyprus
Corporate Taxation
Concept of mutual funds
Adhering to tax residency requirements and maintaining
management and control in Cyprus, a UCITS in the form of a
VCIC will be eligible for the enjoyment of:
As per guidance provided by the Tax Authorities, the concept
of a mutual fund includes the following organisations
(qualifying funds):
• 12,5% Corporate Income Tax rate on income accrued from
the carrying out of the UCITS operations following the
deduction of expenses incurred wholly and exclusively in
the production of income including but not limited to office
costs, payroll and outsourcing costs; and
• Organizations of open-ended collective investment funds
in floating securities (UCITS) which receive establishment
permission from the Securities and Exchange
Commission;
• no withholding tax on income repatriation by the UCITS to
non-resident shareholders.
• International Collective Investment Schemes of a closed
type, namely collective investment organizations with
fixed capital;
Other Tax Considerations
• UCITS registered in other Member States adopting the
European Directive 85/611/EC which are approved by the
Securities and Exchange Commission;
• Cyprus offers a number of tax benefits, including:
o Exemption from tax on incoming dividends subject to
moderate conditions;
o No minimum participation threshold or holding period
requirement on inbound dividends to qualify for tax
exemption;
o Exemption from tax on income arising from trading
in securities. The term ‘Securities’ includes but is not
limited to: shares and share options as well as other
options on titles, debentures, bonds and rights of
claims thereon, participations in companies, units in
open-ended or closed-ended collective investment
schemes such as Mutual Funds, Alternative Investment
Funds (AIFs) and other Undertakings for Collective
Investments in Transferable Securities (UCITS);
o Interest received by regulated UCITS will be
considered ‘active’ interest income and therefore taxed
only at 12,5% corporate income tax;
o Extensive Double Tax Treaty Network (more than 45
treaties concluded); and
o Full harmonisation with all EU Tax Directives.
Indirect Tax
The Cyprus VAT Act (N95(I)/2000) provides that services with
regards to the management (fund management services) of
mutual funds are exempted for VAT purposes (Schedule 7,
Table B, paragraph 3 (f)). The Cyprus VAT Act provides specific
guidance with respect to the meaning of “mutual funds”
and “fund management services” that qualifies for the VAT
exemption.
• Investment funds (in floating securities) by Member
States not adopting the European Directive as well as
by non-Member States to which a necessary approval
is granted by the Securities and Exchange Commission
to make available in the Republic, either directly
from the management company or by its accredited
representatives;
• Any collective investment schemes approved by the
Central Bank of Cyprus.
Fund management services
The following fund management services can benefit from
the VAT exemption. Specific guidance is provided by the Tax
Authorities as to what services are included under each of the
below categories of services:
• Investment management;
•Administration;
• Promotion and Marketing.
A fund management company providing fund management
services needs to examine whether (a) the services it
provides fall under each of the above categories and (b) if
these services are provided to a qualifying fund. Where the
services provided do not fall under the provisions of the fund
management services or they not provided to a qualifying
fund then these will be subject to the standard rate of VAT
(currently 19%).
VAT registration in Cyprus
The transactions carried out by UCITS in the form of a VCIC
may constitute economic activities for VAT purposes. In
such case, the UCITS VCIC may be liable for VAT registration
in Cyprus where it receives taxable services from abroad
exceeding the registration threshold of EUR 15.600.
A guide to UCITS funds in Cyprus
27
28 | Alternative Investment Fund Managers (AIFMD)
How Can KPMG Help?
KPMG Cyprus holds a market leader position in the area of
fund services.
We operate through fully integrated teams that include
professionals across our Audit, Tax and Advisory practices
who combine a wide range of skills and experience tailored
to meet the individual requirements of our clients. All teams
have a rich experience and commitment, ensuring that clients
will be working with teams that understand them, their
needs and the market. We have been and are continuously
involved in the development of policy and regulation in this
sector in Cyprus.
Our Services in connection with the establishment and
operation of a UCITS include, but are not limited to:
Regulatory and Compliance Services
License application
• support in UCITS licence applications (which includes
acting as Promoter of the UCITS throughout the application
process with CySEC) or UCITS registrations;
• complete/review necessary application forms/
questionnaires of the shareholders/directors;
• prepare/review documentation, including the following,
related to the application prior to submission:
oProspectus;
oRegulations or instruments of incorporation;
oKIID;
• identify service providers and facilitate agreement between
them and the UCITS.
Operational compliance
• review and amendment of regulations or instruments of
incorporation and/or Prospectus in order to safeguard
compliance with the UCI Law;
• review of delegation agreements and other agreements to
be entered into by the UCITS and its key counterparties
(depositary, administrator, etc) to safeguard compliance
with the requirements of the UCI Law, performing
notifications to the relevant supervisory authority in case of
delegation of tasks by the Management Company;
• periodic reviews on compliance of UCITS with applicable
laws and regulations.
Audit and Regulatory Reporting Services
• conduct audit of the statutory annual financial statements
based on International Financial Reporting Standards;
• provide support in the design and implementation of the
required reporting framework under the UCI Law.
Direct and Indirect Tax Services
• fund structuring and transaction analysis;
• preparation and submission of corporate tax returns;
• tax due diligence services examining and ensuring the
correct implementation of the relevant laws;
• reports that address and aim to detect and correct issues
that may violate tax laws, as well as provide alternative
solutions to management so as to be updated on the
possible tax implications that may arise and deter the
possibility of omissions in the future;
• international tax planning and implementation of crossborder investments and transactions with the best possible
tax management, fully taking advantage of the provisions
of the European acquis;
• review of the activities of the UCITS in order to identify
potential VAT registration and VAT recoverability position;
• obtain a VAT ruling from the Tax Authorities with regards to
the VAT treatment of the UCITS company activities;
• assistance with the UCITS’ VAT registration;
• assistance with the preparation and submission of VAT
returns;
• review of the agreements for the fund management
services in order to establish whether they fall under the
VAT exemption;
• obtain a VAT ruling from the Tax Authorities on behalf of the
UCITS Management Company in order to establish the VAT
treatment of their services.
Advisory Services
We can also assist you in a variety of other services,
including, but not limited to:
• provide Transaction Advisory services throughout each
phase of a deal process for all types of transactions;
• assist on valuation and accounting treatment of different
financial instruments;
• fund listing;
• locate qualified executive and non-executive directors;
• design a reporting and governance framework;
• review existing risk management and governance
processes of the fund and identify areas for improvement
and cost efficiencies;
• set up quantitative measures for the management of credit
market liquidity and concentration risk;
• conduct an enterprise risk assessment, evaluating the
current state of risk management practice and the
development of a practical road map for achieving the
desired risk management end-state;
• develop an Anti-Money Laundering Procedures Manual
within the context of the law, for the prevention and
suppression of money laundering activities and terrorist
financing;
• assist in the design and implementation of an IT
architecture and automation of business processes;
• develop and implement business continuity and disaster
recovery plans;
• FATCA compliance services.
A guide to UCITS funds in Cyprus
29
©2014 KPMG Limited, a Cyprus limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Main Contacts
REGULATORY & COMPLIANCE
AUDIT
Angelos Gregoriades
Chairman
T: +357 22 209 245
E: [email protected]
Christos Vasiliou
Deputy Managing Director
Primary Contact
T: +357 22 209 113
E: [email protected]
Marie-Helene Angelides
Senior Associate, Legal Advisor
T: + 357 22 209 227
E: [email protected]
Christiana Loizou
Senior Associate, Legal Advisor
T: + 357 22 209 235
E: [email protected]
TAX
Costas Markides
Board Member
T: +357 22 209 246
E: [email protected]
Michael Halios
Board Member
T: +357 24 200 222
E: [email protected]
Tassos Yiasemides
Board Member
T: +357 22 209 156, T: +357 26 955 285
E: [email protected]
ADVISORY
Iacovos Ghalanos
Board Member
T: +357 22 209 029
E: [email protected]
Marios Lazarou
Board Member
T: +357 22 209 107
E: [email protected]
Demetris Vakis
Board Member
T: +357 22 209 301
E: [email protected]
Constantinos Kallis
Board Member
T: +357 22 209 029
E: [email protected]
Costas Kalias
Board Member
T: +357 22 209 133
E: [email protected]
Haris Kakoullis
Board Member
T: +357 22 209 191
E: [email protected]
Zakis Hadjizacharias
Board Member
T: +357 25 869 139
E: [email protected]
Paris Elia
Board Member
T: +357 24 200 112
E: [email protected]
VAT
Harry Charalambous
Board Member
T: +357 22 209 300
E: [email protected]
Contact us
Nicosia
T: +357 22 209 000
F: +357 22 678 200
E: [email protected]
Limassol
T: +357 25 869 000
F: +357 25 363 842
E: [email protected]
Larnaca
T: +357 24 200 000
F: +357 24 200 200
E: [email protected]
Paralimni
T: +357 23 820 080
F: +357 23 820 084
E: [email protected]
Paphos
T: +357 26 943 050
F: +357 26 943 062
E: [email protected]
Polis Chrysochous
T: +357 26 322 098
F: +357 26 322 722
E: [email protected]
www.kpmg.com.cy
©2016 KPMG Limited, a Cyprus limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in Cyprus.
KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”) a Swiss entity.
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to
provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the
future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.
The views and opinions expressed herein are those of the author and do not necessarily represent the views and opinions of KPMG International Cooperative (“KPMG
International”) or KPMG member firms.
220116